Individual IRAC Case Analysis Mind Map

1. Rule of Law

1.1. The court will examine this case using the Civil Rights Act of 1964, specifically Title II, and the federal commerce clause. The court will also argue that the motel owner is not allowed to discriminate based on race, gender, religion, etc.

2. Analysis/Application

2.1. The plaintiff, Heart of Atlanta Motel, argued that the application of Title II of the Civil Rights Act of 1964 was unconstitutional because Congress had exceeded the authority to regulate commerce under the statue when applied to the racial discrimination by the motel. The owner of the motel argued that the motel only engaged in local commerce.

2.2. The defendant, The United States, viewed the motel owner's actions of denying African American customers as a blatant violation of the Civil Rights Act of 1964 which made it unlawful to commit racial discrimination in "establishments affecting interstate commerce". The United States argued that the fact that the motel was accessible via state and interstate highways, advertised nationally and within the state and that the majority of guests were from other states (approximately 75%). Based on these facts, the United States felt it was well within its power to regulate the motel's business activities when it came to racial discrimination.

2.3. The Supreme Court ultimately ruled that the United States was acting appropriately when it prohibited future racial discrimination by the motel. The court also ruled that even though the motel may have believed it operated on a local level, Congress has the right to promote interstate commerce if the activities of the local business harm interstate commerce.

3. Conclusion

3.1. The Supreme Court ruled that Congress, through the Commerce Clause can halt discriminatory practices by local businesses that have an impact on interstate commerce through location, advertising, or origin of customers.

4. Importance

4.1. A business professional would care about this case because it showcases how the federal government can use laws like the commerce clause and the Civil Rights Act of 1964 to directly impact business activities. In this case, the Heart of Atalanta Motel was unfairly discriminating potential customers but the federal government would be able to control other businesses if they engage in interstate commerce.

5. Citations

5.1. Cross, F. B., & Miller, R. L. (2018). Heart of Atlanta Motel v. United States. The Legal Environment of Business (10th edition, pp. 73-74). Boston, MA: Cengage Learning

5.2. (Katzenbach v. McClug, 1964)

5.3. (Daniel v. Paul, 1969)

6. Facts

6.1. Parties

6.1.1. Plaintiff – The United States Defendant – Heart of Atlanta Motel Supreme Court of the United States

6.2. What Happened?

6.2.1. The owner of the Heart of Atlanta Motel refused to rent rooms to African Americans on the basis that the motel was not engaged in interstate commerce but instead was “purely of local character”.

6.2.2. The owner brought an action in federal district court to have the Civil Rights Act declared unconstitutional on the ground that Congress had exceeded its authority to regulate commerce.

6.2.3. The district court ruled against the motel owner and stated that the act did not violate and prohibited any further discrimination based on race. The motel owner then appealed the decision and the case went to the Supreme Court.

6.3. Procedural History

6.3.1. State of origination: Georgia Appellate court: United States District Court for the Northern District of Georgia End court: The United States Supreme Court

7. Issue

7.1. 1) To what commerce does the power of the Commerce Clause of the Constitution of the United States extend? 2) Does a private property owner, for which the property is for public use, have the right to refuse to deal with any member of the public due to race, religion, or national origin?

8. Impact

8.1. Katzenbach v. McClung - In this case, a local restaurant owner in Alabama argued that his restaurant could discriminate African Americans because that his restaurant was small and had little impact on interstate commerce. The Supreme Court ruled that the restaurant was subject to the Commerce Clause and Title II of the Civil Rights Act of 1964 based on the fact that most of the food that was sold in the restaurant had moved via interstate commerce.

8.2. Daniel v. Paul - In this case, the Lake Nixon Club attempted to disguise discrimination of African Americans arguing it was a private club. Membership cards were issued to white patrons for $25. The court ruled that the Lake Nixon Club was not a private club because it offered membership to an unlimited number of whites. The court also ruled that the food sold in the snack bars at the club affected interstate commerce. Based on both of these facts the Lake Nixon Club was subject to Title II of the Civil Rights Act of 1964.

9. Influence

9.1. One business practice is the elimination of gender-based restrooms and deciding to install gender neutral restrooms or installing signs which state that the patron has the right to choose the bathroom for the gender they identify with.

9.2. Another business practice is the accommodation of individuals with disabilities. While this was explicitly addressed with the Americans with Disabilities Act, the Civil Rights Act of 1964 provided a framework to address other groups that had been discriminated against.